Hall Data Sync Technologies LLC v. Google Inc.

Filing 24

Order by Hon. Vince Chhabria granting 23 Stipulation to Continue the Deadline to File the Case Management Statement.(knm, COURT STAFF) (Filed on 8/20/2015)

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[ADDITIONAL COUNSEL LISTED ON
SIGNATURE PAGE]

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Steven T. Lowe, Esq. SBN 122208
[e-mail]
Kris LeFan, Esq., SBN 278611
[e-mail]
LOWE & ASSOCIATES, P.C.
11400 Olympic Blvd., Suite 640
Los Angeles, CA 90064
Telephone: [phone]
Facsimile: [phone]

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Hao Ni (pro hac vice pending)
[e-mail]
NI, WANG & MASSAND, PLLC
8140 Walnut Hill Lane, Suite 500
Dallas, TX 75231
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
HALL DATA SYNC TECHNOLOGIES, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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HALL DATA SYNC TECHNOLOGY,
LLC,

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Plaintiff,
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v.
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BOX, INC.,
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Defendant.
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HALL DATA SYNC TECHNOLOGIES
LLC,

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Plaintiff,

JURY TRIAL DEMANDED

vs.

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STIPULATED MOTION AND [PROPOSED]
ORDER FOR RELIEF FROM DEADLINE TO
FILE JOINT CASE MANAGEMENT
CONFERENCE STATEMENT IN RELATED
ACTIONS PURSUANT TO L.R. 16-2(D)

Defendant.

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DROPBOX INC.

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Case Nos. 15-CV-3063-VC, 15-CV-3064-VC,
15-CV-3065-VC

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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC

CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC

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HALL DATA SYNC TECHNOLOGIES
LLC,

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Plaintiff,
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vs.
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GOOGLE INC.
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Defendant.
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC

CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC

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The Parties in the above captioned cases jointly move under Civ. L.R. 16-2(d) for a

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three-day extension to the deadline to submit the Joint Case Management Conference

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Statement (“Joint CMC Statement”) to allow additional time review and submit an agreed upon

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Statement.

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Local Rule 16-2(d) provides that “a party...may seek relief from an obligation imposed

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by Fed. R. Civ. P. 16 or 26 or the Order Setting Initial Case Management Conference.” In this

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case, the Court should exercise its discretion to permit a three-day modification to the deadline

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to submit the Joint CMC Statement. The Parties in these related actions have made their best

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effort to comply with the Court’s August 12th Order (Dkt. 29 in Case No. 15-3063; Dkt. 25 in

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Case No. 15-3064; Dkt. 21 in Case No. 15-3065) setting August 18th as the deadline to submit

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the Parties’ Joint CMC Statement. Since receiving notice of the deadline, the Parties have

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discussed the contents of the Joint CMC Statement telephonically and have also exchanged an

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initial draft of the Statement. Additional time is needed, however, to allow the parties as well

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as their in-house representatives to review the Joint CMC Statement and proposed schedule,

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and to allow further time for the parties to attempt to reach agreement on its contents. The

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extension will also save the Court time and resources reviewing issues that may otherwise be

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worked out between the Parties. Moreover, lead counsel for Google has a hearing scheduled

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before the Honorable Judge Virginia Phillips in the Central District of California on August

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18th, which has made coordination on the Joint CMC Statement difficult.

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In sum, the Parties in these related actions believe that there is good cause for a short

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three-day extension and respectfully request that the Court extend the deadline to submit the

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Joint CMC Statement from August 18, 2015 to August 21, 2015. No other deadline will be

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affected by this extension (including the Case Management Conference itself).

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IT IS HEREBY STIPULATED AND AGREED, by and among the parties and their

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respective counsel of record and with the permission of the Court, that deadline to submit the

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Parties Initial Case Management Statement in this action shall be continued to Friday,

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August 21, 2015.

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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC

-1-

CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC

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Dated: August 18, 2015

RESPECTFULLY SUBMITTED,
LOWE & ASSOCIATES, P.C.

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BY: /s/Kris LeFan___________________________
KRIS LEFAN

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ATTORNEYS FOR PLAINTIFF
HALL DATA SYNC TECHNOLOGIES, LLC

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Dated: August 18, 2015
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KASOWITZ, BENSON, TORRES & FRIEDMAN
LLP
BY: /s/__John Downing
JEFFREY J. TONEY
JONATHAN K. WALDROP
DARCY L. JONES
MARCUS A. BARBER
ROBERT P. WATKINS III
JOHN W. DOWNING
HEATHER S. KIM

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ATTORNEYS FOR DEFENDANT
GOOGLE INC.

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Dated: August 18, 2015

DLA PIPER LLP (US)

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BY: _/s/_AARON WAINSCOAT
JOHN GUARAGNA
AARON WAINSCOAT

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ATTORNEYS FOR DEFENDANT
BOX INC.

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Dated: August 18, 2015

FARELLA BRAUN + MARTEL LLP

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BY: _/s/_JEFFREY FISHER
Jeffrey M. Fisher
Deepak Gupta
Winston Liaw

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ATTORNEYS FOR DEFENDANT
DROPBOX INC.

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I hereby attest pursuant to L.R. 5.1(i)(3) that concurrence in the electronic filing of this
document has been obtained from the other signatories.

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Dated: August 18, 2015

_/s/ KRIS LEFAN______________________

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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC

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CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC

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[PROPOSED] ORDER

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The Court having considered the stipulation of the parties, orders as follows:

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

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The parties shall file a Joint Case Management Statement on or before Friday,
August 21, 2015.

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PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.

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August 20
Dated: ______________, 2015
Honorable Vince Chhabria
United States District Judge

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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC

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CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC